ETHICS, INTEGRITY AND COMPLIANCE

The Group bases its activities on the highest ethical and integrity standards. We are committed to acting in accordance with the principles set out in the company’s Code of Ethics, an integral part of the Organization, Management and Control Model adopted pursuant to Legislative Decree No 231/01 (“231 Model”), including values of lawfulness, fairness, honesty, integrity, fight against corruption, efficiency, diligence, impartiality, equality and non-discrimination, protection of human resources, environment protection, collaboration and engagement with stakeholders.

The Code of Ethics applies to all its recipients, namely directors, statutory auditors, workers of the company’s audit firm, employees, including directors, as well as anyone outside the company that directly or indirectly operates for Arpinge (e.g., representatives, agents, collaborators in any capacity, consultants, suppliers, business partners). Furthermore, the companies belonging to the Arpinge group require the contractual parties involved from time to time to read the 231 Model and the Code of Ethics of the company concerned and to accept its principles and provisions, as well as to act in accordance with Legislative Decree 231/2001. Any breach constitutes grounds to terminate the contract.

To learn more, read the Group Code of Ethics.

At the governance level, the key principles inspiring Arpinge are management autonomy, transparency and traceability of decision-making processes, professionalism and collegiality of management decisions.

The Group has also established its own internal control and risk management system, consisting of a set of rules, procedures and organizational structures aimed at effectively managing the main risks, to contribute to the sustainable success of Arpinge.

In particular, the main risk areas identified have been regulated through a comprehensive set of procedures, which is the company’s Manual of Procedures.

Furthermore, the Organizational System of Internal Controls defines the main and general criteria for the identification, assessment, measurement, management and reporting of the main risks for business operation.

Organization, Management and Control Model pursuant to Legislative Decree No 231/2001

As part of the monitoring procedures, the Arpinge group has drawn up the 231 Model and set up the Oversight Body.

The 231 Model is a strong reference point for Arpinge and its direct and indirect subsidiaries, to ensure the operational fairness and transparency that characterizes the company’s shareholding and management. Thanks to the Model, it has been possible to align the company’s governance with market best practices, based on effectiveness, efficiency and proportionality criteria, in order to ensure the fairness and transparency of the decision-making processes.